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140 results for “penalty u/s 271”+ Section 10(46)clear

Sorted by relevance

Delhi1,169Mumbai939Ahmedabad304Jaipur245Bangalore204Chennai140Kolkata129Karnataka125Hyderabad123Raipur121Indore117Pune94Chandigarh78Rajkot69Surat53Lucknow37Calcutta34Nagpur33Visakhapatnam29Amritsar27Allahabad25Cochin18Cuttack17Dehradun16Agra15Kerala14Guwahati10Ranchi5Jabalpur5Jodhpur4SC4Telangana3Panaji2Varanasi2Rajasthan1Patna1

Key Topics

Section 271(1)(c)56Addition to Income55Penalty51Section 143(3)37Section 40A(3)26Disallowance26Section 14A25Section 14824Survey u/s 133A

M/S.ENRICA ENTERPRISES PVT LTD,CHENNAI vs. DCIT,CENTRAL CIRCLE-3(4), CHENNAI

In the result, appeal filed by the assessee in ITA

ITA 1165/CHNY/2023[2016-17]Status: DisposedITAT Chennai06 Mar 2024AY 2016-17

Bench: Shri Manjunatha. G & Shri Manomohan Das

Section 271Section 271(1)(C)Section 271ASection 274

u/s 274 r.w.s 271 was a vague notice in a printed form without specifying the exact charge for which the assessee was being penalized and therefore, it was a clear case of non-application of mind while initiating penalty against the assessee. The Ld. AO, while initiating the penalty was not clear as to specific limb which was applicable

M/S ENRICA ENTERPRISES PVT LTD,CHENNAI vs. DCIT,CENTRAL CIRCLE-3(4), CHENNAI

In the result, appeal filed by the assessee in ITA

Showing 1–20 of 140 · Page 1 of 7

21
Section 271(1)20
Section 27119
Section 13216
ITA 1164/CHNY/2023[2015-16]Status: DisposedITAT Chennai06 Mar 2024AY 2015-16

Bench: Shri Manjunatha. G & Shri Manomohan Das

Section 271Section 271(1)(C)Section 271ASection 274

u/s 274 r.w.s 271 was a vague notice in a printed form without specifying the exact charge for which the assessee was being penalized and therefore, it was a clear case of non-application of mind while initiating penalty against the assessee. The Ld. AO, while initiating the penalty was not clear as to specific limb which was applicable

ST. JOSEPHS INSTITUTE OF SCIENCE AND TECHNOLOGY TRUST,CHENNAI vs. DCOT. CENTRAL CIRCLE-1(3), CHENNAI

In the result, all the appeals filed by the assessees are allowed

ITA 3295/CHNY/2024[2018-19]Status: DisposedITAT Chennai06 Jun 2025AY 2018-19

Bench: Shri Aby T. Varkey & Shri Jagadish

For Appellant: Mr. V. Balaji, CA &For Respondent: Ms. Anitha, Addl.CIT
Section 11Section 12ASection 139(1)Section 143(1)Section 270ASection 271A

271(1)(c) of the Act, the same principle would equally apply to Section 271AAB of the Act Further, the Ld.DR reliance on the decision of the Hon’ble Bombay High Court in the case of CIT Vs Kaushalya (1995) 216 ITR 660 (Bom) do not death with the section 292B of the Act at all. Further, this decision only

ST.JOSEPHS EDUCATIONAL TRUST,CHENNAI vs. DCIT, CENTRAL CIRCLE-193), CHENNAI

In the result, all the appeals filed by the assessees are allowed

ITA 3293/CHNY/2024[2018-19]Status: DisposedITAT Chennai06 Jun 2025AY 2018-19

Bench: Shri Aby T. Varkey & Shri Jagadish

For Appellant: Mr. V. Balaji, CA &For Respondent: Ms. Anitha, Addl.CIT
Section 11Section 12ASection 139(1)Section 143(1)Section 270ASection 271A

271(1)(c) of the Act, the same principle would equally apply to Section 271AAB of the Act Further, the Ld.DR reliance on the decision of the Hon’ble Bombay High Court in the case of CIT Vs Kaushalya (1995) 216 ITR 660 (Bom) do not death with the section 292B of the Act at all. Further, this decision only

R.MAHALAKSHMI,CHENNAI vs. ACIT NON CORPORATE CIRCLE 17(1), CHENNAI

In the result, the assessee’s appeal is dismissed

ITA 3106/CHNY/2018[2008-09]Status: DisposedITAT Chennai10 Sept 2019AY 2008-09

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaramanआयकर अपील सं./I.T.A.No.3106/Chny/2018 (िनधा"रण वष" / Assessment Year: 2008-09) Vs The Acit, Smt. R. Mahalakshmi, No.24, Abm Avenue, Non-Corporate Circle – 17(1), Chennai. R.A. Puram, Chennai – 600 028. Pan: Agqpm8406N (अपीलाथ"/Appellant) (""थ"/Respondent)

For Appellant: Shri G. Baskar, AdvocateFor Respondent: Shri Gurubashyam, JCIT
Section 132(4)Section 139Section 153ASection 271(1)(c)Section 271A

46,30,500/-. Subsequently, on issue of notice u/s. 153A, the assessee filed a return admitting the total income of Rs.2,02,62,800/- on 29.10.2010, in which she has claimed Rs.6,50,000/-towards agricultural income which was not declared in the original return. After examining the facts and circumstances of the assessee’s case, the Assessing Officer levied

SHRI MAHAVEERCHAND JAIN,CHENNAI vs. DCIT,CC4(2), CHENNAI

The appeals stand allowed on similar lines

ITA 909/CHNY/2020[2002-03]Status: DisposedITAT Chennai13 May 2022AY 2002-03

Bench: Hon’Ble Shri Mahavir Singh & Hon’Ble Shri Manoj Kumar Aggarwal, Am

For Appellant: Shri D. Anand (Advocate) – Ld. ARFor Respondent: Shri G. Johnson (Addl. CIT) –Ld. Sr. DR
Section 271Section 271(1)(c)Section 274

46, M.G. Road, Chennai -34 at 3 AM/PM on 04.05.2006 and show cause why an order imposing a penalty on you should not be made under section 271 of the Income Tax Act, 1961. If you do not wish to avail yourself of this opportunity of being heard in person or through authorized representative your may show cause in writing

SHRI MAHAVEERCHAND JAIN,CHENNAI vs. DCIT,CC4(2), CHENNAI

The appeals stand allowed on similar lines

ITA 905/CHNY/2020[1998-99]Status: DisposedITAT Chennai13 May 2022AY 1998-99

Bench: Hon’Ble Shri Mahavir Singh & Hon’Ble Shri Manoj Kumar Aggarwal, Am

For Appellant: Shri D. Anand (Advocate) – Ld. ARFor Respondent: Shri G. Johnson (Addl. CIT) –Ld. Sr. DR
Section 271Section 271(1)(c)Section 274

46, M.G. Road, Chennai -34 at 3 AM/PM on 04.05.2006 and show cause why an order imposing a penalty on you should not be made under section 271 of the Income Tax Act, 1961. If you do not wish to avail yourself of this opportunity of being heard in person or through authorized representative your may show cause in writing

SHRI MAHAVEERCHAND JAIN,CHENNAI vs. DCIT,CC4(2), CHENNAI

The appeals stand allowed on similar lines

ITA 907/CHNY/2020[2000-01]Status: DisposedITAT Chennai13 May 2022AY 2000-01

Bench: Hon’Ble Shri Mahavir Singh & Hon’Ble Shri Manoj Kumar Aggarwal, Am

For Appellant: Shri D. Anand (Advocate) – Ld. ARFor Respondent: Shri G. Johnson (Addl. CIT) –Ld. Sr. DR
Section 271Section 271(1)(c)Section 274

46, M.G. Road, Chennai -34 at 3 AM/PM on 04.05.2006 and show cause why an order imposing a penalty on you should not be made under section 271 of the Income Tax Act, 1961. If you do not wish to avail yourself of this opportunity of being heard in person or through authorized representative your may show cause in writing

SHRI MAHAVEERCHAND JAIN,CHENNAI vs. DCIT CC4(2), CHENNAI

The appeals stand allowed on similar lines

ITA 908/CHNY/2020[2001-02]Status: DisposedITAT Chennai13 May 2022AY 2001-02

Bench: Hon’Ble Shri Mahavir Singh & Hon’Ble Shri Manoj Kumar Aggarwal, Am

For Appellant: Shri D. Anand (Advocate) – Ld. ARFor Respondent: Shri G. Johnson (Addl. CIT) –Ld. Sr. DR
Section 271Section 271(1)(c)Section 274

46, M.G. Road, Chennai -34 at 3 AM/PM on 04.05.2006 and show cause why an order imposing a penalty on you should not be made under section 271 of the Income Tax Act, 1961. If you do not wish to avail yourself of this opportunity of being heard in person or through authorized representative your may show cause in writing

SHRI MAHAVEERCHAND JAIN,CHENNAI vs. DCIT,CC4(2), CHENNAI

The appeals stand allowed on similar lines

ITA 912/CHNY/2020[2005-06]Status: DisposedITAT Chennai13 May 2022AY 2005-06

Bench: Hon’Ble Shri Mahavir Singh & Hon’Ble Shri Manoj Kumar Aggarwal, Am

For Appellant: Shri D. Anand (Advocate) – Ld. ARFor Respondent: Shri G. Johnson (Addl. CIT) –Ld. Sr. DR
Section 271Section 271(1)(c)Section 274

46, M.G. Road, Chennai -34 at 3 AM/PM on 04.05.2006 and show cause why an order imposing a penalty on you should not be made under section 271 of the Income Tax Act, 1961. If you do not wish to avail yourself of this opportunity of being heard in person or through authorized representative your may show cause in writing

SHRI MAHAVEERCHAND JAIN,CHENNAI vs. DCIT,CC4(2), CHENNAI

The appeals stand allowed on similar lines

ITA 910/CHNY/2020[2003-04]Status: DisposedITAT Chennai13 May 2022AY 2003-04

Bench: Hon’Ble Shri Mahavir Singh & Hon’Ble Shri Manoj Kumar Aggarwal, Am

For Appellant: Shri D. Anand (Advocate) – Ld. ARFor Respondent: Shri G. Johnson (Addl. CIT) –Ld. Sr. DR
Section 271Section 271(1)(c)Section 274

46, M.G. Road, Chennai -34 at 3 AM/PM on 04.05.2006 and show cause why an order imposing a penalty on you should not be made under section 271 of the Income Tax Act, 1961. If you do not wish to avail yourself of this opportunity of being heard in person or through authorized representative your may show cause in writing

SHRI MAHAVEERCHAND JAIN,CHENNAI vs. DCIT,CC4(2), CHENNAI

The appeals stand allowed on similar lines

ITA 911/CHNY/2020[2004-05]Status: DisposedITAT Chennai13 May 2022AY 2004-05

Bench: Hon’Ble Shri Mahavir Singh & Hon’Ble Shri Manoj Kumar Aggarwal, Am

For Appellant: Shri D. Anand (Advocate) – Ld. ARFor Respondent: Shri G. Johnson (Addl. CIT) –Ld. Sr. DR
Section 271Section 271(1)(c)Section 274

46, M.G. Road, Chennai -34 at 3 AM/PM on 04.05.2006 and show cause why an order imposing a penalty on you should not be made under section 271 of the Income Tax Act, 1961. If you do not wish to avail yourself of this opportunity of being heard in person or through authorized representative your may show cause in writing

SHRI MAHAVEERCHAND JAIN,CHENNAI vs. DCIT,CC4(2), CHENNAI

The appeals stand allowed on similar lines

ITA 906/CHNY/2020[1999-2000]Status: DisposedITAT Chennai13 May 2022AY 1999-2000

Bench: Hon’Ble Shri Mahavir Singh & Hon’Ble Shri Manoj Kumar Aggarwal, Am

For Appellant: Shri D. Anand (Advocate) – Ld. ARFor Respondent: Shri G. Johnson (Addl. CIT) –Ld. Sr. DR
Section 271Section 271(1)(c)Section 274

46, M.G. Road, Chennai -34 at 3 AM/PM on 04.05.2006 and show cause why an order imposing a penalty on you should not be made under section 271 of the Income Tax Act, 1961. If you do not wish to avail yourself of this opportunity of being heard in person or through authorized representative your may show cause in writing

ACIT, CHENNAI vs. M/S. S & P FOUNDATION P. LTD., CHENNAI

In the result, the appeal filed by the Revenue is allowed

ITA 2084/CHNY/2013[2006-07]Status: DisposedITAT Chennai16 Dec 2021AY 2006-07

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. No.2084/Chny/2013 िनधा"रण वष"/Assessment Years: 2006-07 The Assistant Commissioner Of M/S. S & P Foundation P. Ltd., Income Tax, Central Circle Iv(2), Vs. Old No. 27, New No. 38, Madley Road, 46, Nungambakkam High Road, T. Nagar, Chennai 600 017. Chennai. [Pan: Aaics0224K] (अपीलाथ" /Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By Shri G. Johnson, Addl. Cit : ""थ" की ओर से/Respondent By Shri G. Baskar, Advocate & : Shri I Dinesh, Advocate सुनवाई की तारीख/ Date Of Hearing 02.12.2021 : घोषणा की तारीख /Date Of Pronouncement : 16.12.2021 आदेश /O R D E R Per V. Durga Rao: This Appeal Filed By The Revenue Is Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals) Ii, Chennai, Dated 05.12.2012 Relevant To The Assessment Year 2006-07 In Pursuance To The Order Of The Assessing Officer In Levying Penalty Under Section 271(1)(C) Of The Income Tax Act, 1961 [“Act” In Short].

Section 153ASection 271(1)(c)Section 3

u/s 271(1)(c). In this regard we rely on the Supreme Court order dt. 17.03.2010 in the case of CIT, Ahmedabad Vs. Reliance Petroproducts Pvt. Ltd. We pray that, as our case does not attract levy of penalty, the proceedings may be dropped.” 15. During the course of penalty proceedings, by considering the explanation of the assessee, the Assessing

MUTHURATHINAM,TIRUPPUR vs. ITO, WARD-1(2), TIRUPPUR

In the result, appeal filed by the assessee is allowed

ITA 2656/CHNY/2024[2013-14]Status: DisposedITAT Chennai27 Jan 2025AY 2013-14

Bench: Hon’Ble Shri Manoj Kumar Aggarwal & Hon’Ble Shri Manu Kumar Giriआयकरअपील सं./ Ita No.2656/Chny/2024 (िनधा"रणवष" / Assessment Year: 2013-2014) Muthurathinam, Vs. The Income Tax Officer, 27/29, Kumarappapuram, Ward 1(2) 1St Street, Rayapuram Extension, Tirupur. Tirupur 641 601. [Pan: Avypm 0862D] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Shri. S. Sridhar, (Erode) Advocate By Virtual. ""यथ" क" ओर से /Respondent By : Ms. Anitha, Irs, Addl. Cit. सुनवाई क" तार"ख/Date Of Hearing : 31.12.2024 घोषणा क" तार"ख /Date Of Pronouncement : 27.01.2025 आदेश / O R D E R Per Manu Kumar Giri () This Penalty Appeal Filed By The Assessee Is Directed Against The Order Of The National Faceless Appeal Centre (Nfac), Delhi [Cit(A)] Dated 21.08.2024 For Assessment Year 2013-14. 2. The Issue Sought To Be Urged By The Assessee In This Appeal Is Whether The Cit(A) Was Justified In Upholding The Penalty Under Section 271(1)(C) Of The Income Tax Act, 1961 ["Act"] By Ignoring The Fact That The Assessing Officer (‘Ao’ In Short) In Assessment Order Dated 28.09.2021 Has Satisfied That Penalty Proceeding Is Being Initiated Separately For “Furnishing Of Inaccurate Particulars Of Such Income” Where As Penalty Order U/S 271(1)(C) Dated 04.01.2022 Levied Penalty For “Concealment Of Income”, Although In The Notice Under Section 274 Read With Section 271(1) (C), The Ao Has Marked The Specified Limb As “That You Have Furnished Inaccurate Particulars Of Such Income”.

For Appellant: Shri. S. Sridhar, (Erode) Advocate by virtualFor Respondent: Ms. Anitha, IRS, Addl. CIT
Section 143(2)Section 143(3)Section 148Section 151Section 271Section 271(1)Section 271(1)(c)Section 274Section 44A

46,770/- by disclosing additional income of Rs.19,98,843/- under the head "Income from other sources". Thereafter, notices u/s. 143(2) and 142(1) were issued and the appellant had submitted his replies. The assessment was completed u/s. 143(3) r.w.s. 147 of the Act on 28.09.2021 by accepting revised total income as disclosed in the return of income

PENTA MEDIA GRAPHICS LTD.,CHENNAI vs. DCIT, CHENNAI

In the result, the appeal filed by the assessee is dismissed

ITA 1402/CHNY/2015[2000-01]Status: DisposedITAT Chennai10 May 2023AY 2000-01

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. No.1402/Chny/2015 िनधा"रण वष"/Assessment Year: 2000-01 M/S. Penta Media Graphics Ltd., The Deputy Commissioner Of ‘Taurus’, No. 25, First Main Road, Vs. Income Tax, Media Circle I, Room No. 311, 3Rd Floor, New Block, United India Colony, Kodambakkam, Chennai 600 024. 121, Mahatma Gandhi Road, Nungambakkam, Chennai 600 034. [Pan: Aaacp1647B] (अपीलाथ" /Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By Shri G. Baskar, Advocate & : Smt. Sree Valli Lakshmi, Advocate ""थ" की ओर से/Respondent By None [Dept. Letter Submission] : सुनवाई की तारीख/ Date Of Hearing 12.04.2023 : घोषणा की तारीख /Date Of Pronouncement : 10.05.2023 आदेश /O R D E R Per V. Durga Rao: This Appeal Filed By The Assessee Is Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals) 14, Chennai Dated 30.03.2015 Passed Under Section 271(1)(C) Of The Income Tax Act, 1961 [“Act” In Short].

Section 143(3)Section 271(1)(c)

section 271(1)(c) of the Act and issued show-cause notice dated 15.03.2012. The assessee filed its reply dated 21.03.2012 by stating that the penalty proceedings may be dropped. The content of the assessee’s reply is reproduced as under: In the return of income filed for the A.Y.2000-01 the assessee-company had claimed exemption u/s 1OB in respect

DR.S.F.V.SELVARAJ,CHENNAI vs. DCIT, CHENNAI

In the result, both the appeals filed by the assessee are dismissed

ITA 869/CHNY/2016[2012-13]Status: DisposedITAT Chennai06 Jul 2022AY 2012-13

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. Nos.868 & 869/Chny/2016 िनधा"रण वष"/Assessment Year:2012-13 Dr. (Late) S.F.V. Selvaraj, The Deputy Commissioner Of Rep. By L/H Dr. Kamala Selvaraj, Vs. Income Tax, Dr. Deepu Rajkamal Selvaraj, Dr. Priya Central Circle 2(5), Selvaraj, No. 22, 5Th Street, Dr. Chennai. Thirumurthy Nagar, Nungambakkam, Chennai 600 034. [Pan:Aasps5404L] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri G. Baskar, Advocate ""थ" की ओर से/Respondent By : Shri M. Rajan, Cit सुनवाई की तारीख/ Date Of Hearing : 17.05.2022 घोषणा की तारीख /Date Of Pronouncement : 06.07.2022 आदेश /O R D E R Per V. Durga Rao: Both Appeals Filed By The Assessee Are Directed Against Separate Orders Of The Ld. Commissioner Of Income Tax (Appeals) 18, Chennai, Both Dated 08.02.2016 Relevant To The Assessment Year 2012-13 Challenging The Confirmation Of Quantum Addition Of Unexplained Cash Under Section 69A Of The Income Tax Act, 1961 [“Act” In Short] & Confirmation Of Penalty Levied Under Section 271Aaa Of The Act. Against Quantum Addition, The Assessee Has Raised The Following Grounds:

For Appellant: Shri G. Baskar, AdvocateFor Respondent: Shri M. Rajan, CIT
Section 132Section 271ASection 69A

46,10,095, was found in the assessee's consultation room on the ground floor of GG Hospital. Of this Rs.45,45,000 was seized. The authorised officer questioned about this at the time of search vide question number 56. For this the assessee replied as under. "As explained to you, it is my long-term professional income, but which

DR.S.F.V.SELVARAJ,CHENNAI vs. DCIT, CHENNAI

In the result, both the appeals filed by the assessee are dismissed

ITA 868/CHNY/2016[2012-13]Status: DisposedITAT Chennai06 Jul 2022AY 2012-13

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. Nos.868 & 869/Chny/2016 िनधा"रण वष"/Assessment Year:2012-13 Dr. (Late) S.F.V. Selvaraj, The Deputy Commissioner Of Rep. By L/H Dr. Kamala Selvaraj, Vs. Income Tax, Dr. Deepu Rajkamal Selvaraj, Dr. Priya Central Circle 2(5), Selvaraj, No. 22, 5Th Street, Dr. Chennai. Thirumurthy Nagar, Nungambakkam, Chennai 600 034. [Pan:Aasps5404L] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri G. Baskar, Advocate ""थ" की ओर से/Respondent By : Shri M. Rajan, Cit सुनवाई की तारीख/ Date Of Hearing : 17.05.2022 घोषणा की तारीख /Date Of Pronouncement : 06.07.2022 आदेश /O R D E R Per V. Durga Rao: Both Appeals Filed By The Assessee Are Directed Against Separate Orders Of The Ld. Commissioner Of Income Tax (Appeals) 18, Chennai, Both Dated 08.02.2016 Relevant To The Assessment Year 2012-13 Challenging The Confirmation Of Quantum Addition Of Unexplained Cash Under Section 69A Of The Income Tax Act, 1961 [“Act” In Short] & Confirmation Of Penalty Levied Under Section 271Aaa Of The Act. Against Quantum Addition, The Assessee Has Raised The Following Grounds:

For Appellant: Shri G. Baskar, AdvocateFor Respondent: Shri M. Rajan, CIT
Section 132Section 271ASection 69A

46,10,095, was found in the assessee's consultation room on the ground floor of GG Hospital. Of this Rs.45,45,000 was seized. The authorised officer questioned about this at the time of search vide question number 56. For this the assessee replied as under. "As explained to you, it is my long-term professional income, but which

M/S ENRIA ENTERPRISES PVT. LTD,CHENNAI vs. DCIT. CENTRAL CIRCLE - 3(4), CHENNAI

In the result, appeal filed by the assessee in ITA

ITA 1167/CHNY/2023[2018-19]Status: DisposedITAT Chennai06 Mar 2024AY 2018-19

Bench: Shri Manjunatha. G & Shri Manomohan Das

For Appellant: Shri D. Anand, AdvFor Respondent: Shri R. Clement Ramesh –
Section 2Section 270Section 270ASection 270A(9)

46,473/- which includes additional income offered during the course of search towards inflated expenditure. In the return of income filed for AYs 2017-18 & 2018-19, the assessee company has offered additional income of Rs.25.73 Crs. & Rs.32.46 Crs. respectively towards additional income offered during the course of search on account of inflated expenditure under the head ‘gift articles’. During

M/S ENRICE ENTERPRISES PVT. LTD,CHENNAI vs. DCIT,CENTRAL CIRCLE-3(4), CHENNAI

In the result, appeal filed by the assessee in ITA

ITA 1166/CHNY/2023[2017-18]Status: DisposedITAT Chennai06 Mar 2024AY 2017-18

Bench: Shri Manjunatha. G & Shri Manomohan Das

For Appellant: Shri D. Anand, AdvFor Respondent: Shri R. Clement Ramesh –
Section 2Section 270Section 270ASection 270A(9)

46,473/- which includes additional income offered during the course of search towards inflated expenditure. In the return of income filed for AYs 2017-18 & 2018-19, the assessee company has offered additional income of Rs.25.73 Crs. & Rs.32.46 Crs. respectively towards additional income offered during the course of search on account of inflated expenditure under the head ‘gift articles’. During